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ARTICLE · 27 APRIL 2017

CFTC Exempts CPO From Annual Filing And Reporting Requirements

Hogan Lovells Cadwalader
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The CFTC Division of Swap Dealer and Intermediary Oversight issued an exemption letter to a commodity pool operator ("CPO") of a number of pools operated pursuant to CFTC Rule 4.7.

United StatesFinance and Banking

The CFTC Division of Swap Dealer and Intermediary Oversight issued an exemption letter to a commodity pool operator ("CPO") of a number of pools operated pursuant to CFTC Rule 4.7. The relief exempts the CPO from having to file with the National Futures Association and distribute an audited annual report to pool participants with respect to each of such pools. Instead, the Division, taking into account the ownership structure and proprietary nature of the pool arrangement (involving subsidiary pools composed of high-level employees), allowed the CPO to file and distribute a consolidated audited annual report to all pool participants.

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